Motions for summary judgment and responses must comply with Local Rule 56.1, as well as the procedures outlined here. 

The statements of undisputed material facts and responses shall be filed separately from the memoranda of law and shall include the line, paragraph, or page number where the supporting material may be found in the record.  Parties must make the supporting evidence easy to find. 

A Local Rule 56.1 statement of facts is not a substitute for a statement of facts section contained in the supporting brief.  A supporting brief that merely incorporates the Local Rule 56.1 statement rather than setting forth a statement of facts section may be stricken. 

 The Local Rules are not mere technicalities.  The Court expects strict compliance with the Local Rules regarding summary judgment.  Failure to comply with the Local Rules may result in the Court striking briefs, disregarding statements of fact, deeming statements of fact admitted, and denying summary judgment.  See Modrowski v. Pigatto, 712 F.3d 1166, 1169 (7th Cir. 2013); Keeton v. Morningstar, Inc., 667 F.3d 877, 884 (7th Cir. 2012).

The movant shall not file more than 80 statements of undisputed material facts without prior leave of Court.  The respondent shall be limited to 40 statements of undisputed material facts absent prior leave of Court.  In complex cases, the Court may request that the parties submit a timeline of events in addition to statements of undisputed material facts.

Motions to strike are disfavored.  If a party contends that another party has included inadmissible evidence, improper argument, or other objectionable material in a Local Rule 56.1 submission, the party typically should raise its argument that the Court should not consider such material in the party’s response or reply brief – not in a separate motion to strike.

Parties must include a table of contents for any exhibits.

Parties submitting deposition transcripts in support of or in opposition to summary judgment must provide the full deposition transcript. Where possible, deposition transcripts should be submitted in the condensed transcript format where multiple deposition transcript pages are reduced to one page.

All electronically filed documents shall be made word searchable before being filed on CM/ECF. For any filing of any kind (including exhibits in support of a motion or any Local Rule 56.1 Statement), counsel must run an OCR conversion on it before uploading it onto CM/ECF. To do this in Adobe, go to Tools, Text Recognition, In This File, and select All Pages. If you see the message, "Acrobat could not perform recognition (OCR) on this page because this page contains renderable text," click "Ignore future errors in this document," and click OK. Counsel must convert any word-processed document into a .pdf by printing or publishing to .pdf, rather than manually scanning a paper copy into .pdf